Andre Adam, sales director at grease manufacturer Fragol GmbH in Mulheim, Germany, is vocal on this point. Clearly and simply, there should be only one food-grade lubricants category, and that should be H1, he states. The whole H2 category is unnecessary. H2 lubricants today are similar to any other product out there. It may have been a useful category many years ago, as assurance that only non-carcinogenic ingredients were used, but such items are not now present in any lubricant products.

Meanwhile, by having H2 lubricants registered for use around food plants, it gives end users a sense of security that is not there. A lubricant either is food-grade or is not, but it cant be in-between, he insists.

What purpose does H2 serve? ponders Bob Whiting, president of Ultrachem Inc. in New Castle, Del. His company makes a large slate of food-grade H1 lubricants, plus others that qualify as H2. Yet he says, It wouldnt matter to us one way or the other if the category disappeared, and it might clear up some misconceptions in the market.

And Paul Bessette, president of Triboscience & Engineering in Fall River, Mass., says, I suspect that H2 is an anachronism, going back to what transpired 50 years ago. Back then, you might have found lubricants made with poorly refined base oils with [carcinogenic] polycyclic aromatic hydro-carbons, or with lead-based extreme-pressure additives. All of those are prohibited now, regardless of whether the lubricant is H1, H2 or anything else. So to keep the H2 category is pointless.

Do we need H2? Probably not from a technical standpoint, but it could depend on how you approach the market, Bessette continues. I cant say how others position themselves, but my feeling is that H2 lubricants are dying a slow death on the vine. Nobody calls me and asks, Can you formulate an H2 lubricant? If Im creating a product for the food industry, I want to put something out there that doesnt pose a risk, and that means H1. No ones ever asked me in 30 years to design an H2 lubricant, only H1..

Another grease formulator, who spoke on condition of anonymity, is pragmatic: I think some customers at food plants may be confused, and if its in their plant, the H2 product could be misapplied inappropriately in the food application. There is that possibility. However, adds this source, who works for a nationally known lubricant marketer, we do have customers asking for H2 lubricants. I think most of these companies are conscientious and do a good job in managing their lubricants, and its good to have something to offer them if they ask for it.

H1 is for use where there may be incidental food contact, and thats the important one, agrees Tony Wenzler, who formulates greases at Battenfeld Grease & Oil Corp. in North Tonawanda, N.Y., where hes director of technical services. H2 is for absolutely no food contact, and in fact almost any product will qualify as H2. Perhaps if they use these anywhere else in the plant, away from the food, customers can feel warm and fuzzy – but thats all theyre getting.

Whats behind it?

As Wenzler reminds, even H1 lubricants are not supposed to have any contact with foodstuffs, and if incidental contact cannot be avoided it must be rigorously minimized. Whats allowed as incidental contact is extremely low, just 10 parts per million of contamination, he says. Any more means that batch of food cannot be sold.

How much is 10 ppm? Its only 10 drops of lubricant in 40 gallons of gin – thats one very dry martini, explains Bessette. To make sure that limit isnt reached, food plants should make sure their equipments seals are in place and working, and that the lubricant cannot drip into the food line.

Two outfits, NSF International in Ann Arbor, Mich., and InS Services in Rugeley, Staffordshire, U.K., register lubricants as meeting H1 and H2. They adhere for the most part to definitions established by the U.S. Department of Agriculture and enforced by its Food Safety Inspection Service. FSIS itself used to review lubricant formulations, and if the ingredients met the criteria spelled out in federal regulations (21 CFR 178.3570), the agency would issue a letter of compliance and include the product in its White Book.

When FSIS stopped reviewing nonfood compounds in 1998, NSF stepped up with a formulary review and registration program, and launched its own White Book, which is kept updated at www.nsf.org. Some years later, InS Services began reviewing, registering and listing products as well, at www.InSServices.eu.

Today, NSF has around 7,000 lubricants listed as meeting the requirements of H1, and 1,000 that are H2. Seeing a market need, NSF also created two corresponding categories for lubricant ingredients, HX-1 and HX-2. It now lists 383 of the former, 105 of the latter.

Before listing any lubricant, NSF stringently reviews its ingredients and their weight percentages in the final formulations, says Jessica Evans, its business unit manager. The H1 and H2 categories are holdovers from the old USDA program which was discontinued. By offering both categories, were trying to serve as much of the market as we can. But H2 is not a food-grade product, and certainly shouldnt be used as such, she says.

Additionally, if a lubricant marketer requests it and pays a fee, NSF will allow an H1 product to join the less-restrictive H2 list, too. Why would a company want a dual listing for the same product? Evans wont speculate, but adds, We cant discourage it. If they get an H1 listing and also want the other, well register the product to that as well.

Its just silly

InS Services lists roughly 1,000 H1 lubricants, and five that meet H2. However, no product gets listed in both. Further, InS steers participants away from registering H2 products at all, according to founder Sid Stone.

H2 is a completely pointless category, Stone says emphatically. If someone insists, we will register to it because it de facto exists, but its a grade that covers anything and so it means nothing. It doesnt mean that the product is suitable for incidental food contact. In fact, you cant use it anywhere near food.

And if a product already has H1, why get H2 as well? We tell our registrants, look, its the same product, you dont need both. If someone really wants it, well list them as H2, but we wont do both. Putting both H1 and H2 on a product is trickery; its not worth paying the fee for another listing.

The only possible use for H2 is to show that the lubricant is not carcinogenic, but so is every other industrial lubricant now, Stone goes on. We dont have the authority to eliminate the category, but if you take these products into a food factory, H2 is not suitable for use where the food might contact it. And to register a product as unsuitable is just silly. We actively discourage it.

Others, however, view dual-listing as harmless, or even good marketing. As long as Im doing an H1 registration and do the H2 at the same initial time, it costs nothing extra, so I just get them both, says Battenfelds Wenzler. Most customers who come to us want the H1 product, only rarely H2. But Im covered if they do!

David DeVore, president of additive manufacturer Functional Products in Macedonia, Ohio, notes that almost every one of his HX-1 tackifiers gets HX-2 as well. We offer HX-2 on our products because it may give formulators some increased flexibility in the design of their products, he explains. We can register them as either HX-1 or HX-2, so we want to give the blender the option.

Also, it matters not to us whether we apply for HX-1 or HX-2, he continues. If we apply at the same time for the same product, theres no incidental cost to us from NSF. As long as were sending a check and paying for one, Ill take the other too.

How to move ahead

Food-grade lubricants are a high-value specialty, with strong demand anticipated from food processors and also plants that make pharmaceuticals, animal feed and food packaging. This leads some cynics to surmise that what Fragol and other H1 lube makers actually want is entree to the market space now filled by H2 products.

Andre Adam scoffs at this. The H2 category is meaningless, he retorts. Whats cynical is to try to maintain it. It just means a lot of paperwork, hassle and nonsense.

And other lubes would also jump into H2s territory, says Wenzler at Battenfeld. If you got rid of the H2 designation, you potentially might be opening the non-contact applications in food plants to competition from regular industrial lubes. But the decision will still be with the end user, whether to use a regular lube or an H1. Do they care? Are they paying attention?

Many say its time to better educate food plant owners about their lube choices. Some would start by not allowing H2 lubes to say theyre food-grade. Others suggest two tiers of labeling, differently colored logos, or something else to distinguish the choices for users. NSF and InS also have been urged to publicize H2s limitations on their websites.

Meanwhile, says DeVore, having both H1 and H2 available does mean there are shades of gray in the food-grade lubes market, and it is confusing to the end user.

Others concur with that assessment, including Adam: The customer has not been educated, so he keeps asking for H2 lubricants. But if any lubricant is toxic or hazardous, it should be marked and categorized as such. I think that having H2 lubes available creates confusion, and gives the customer the excuse, well, Im using H2 lubricants, it must be OK.

If NSF can add categories, as it did with HX-1 and HX-2, it also can drop them, Adam feels. In fact, he points out, even H1 doesnt officially exist now. Its just that NSF has continued to use the same standard after the USDA ended its registration program. So NSF could stop registering products to H2 if it wanted.

Not so fast, says NSFs Evans. This spring was the first wed heard of there maybe being confusion about H2 and food-grade lubricants. We want to move ahead carefully, and not make rash decisions. Definitely the next steps for us at NSF will be better education for the industry. We wont withdraw the category altogether though. For one thing, there would be a very high cost for our customers to redo their labels and marketing materials. If we eliminated H2 listings, they would have to be removed from the market.

We will continue to register H2, and also put more emphasis on educating end users, and to reach out to auditors in the field, she assures.

All in for H1

Not every food plant asks for H2 lubricants. Some companies, like Kraft Foods, have a policy to use H1 lubricants only, everywhere in their plants, says Ultrachems Whiting. Thats how they and other big companies are handling the risk. Those users only buy H1 lubricants, approved for incidental contact. Theyve seen the mishaps and gigantic food recalls. They want to avoid any such risk.

However, substantial numbers of end users still cling to H2 lubes, fearful that H1 products will fall short. That may have been so in the past but not anymore, many suppliers say.

Historically, H1 lubricants didnt have a lot of performance, and a lot of food plants covered that by using H2 lubricants in non-contact areas where they needed more performance, Wenzler says. But today we have some great H1 products, like calcium sulfonate greases and calcium oleates, and a longer list of HX-1 products to work with. We have been able to add some performance to the H1 category.

Whiting concurs. It used to be that H1 lubes were weaker, but now you can make H1s with NSF-registered polyglycols, PAOs and even esters, he says. Theres a much wider selection of base fluids and chemistries.

And Bessette points to recent H1 greases designed for demanding applications, such as PTFE-thickened greases fortified with PFPE, PAO or amorphous silica. Another promising PFPE product, which he hopes soon to beta test, might economically lubricate conveyor chains in bakery ovens, without polymerizing or carbonizing. He believes that if food plants look at their overall cost of operations, not just the up-front cost of the lubricant, they will find synthetic H1 products to be palatable.

Sid Stone at InS sees most food manufacturers today using HACCP (hazard analysis and critical control points) to manage risk in their plant processes, and that includes decisions about what lubricants to use where. Whatever reason there may have been at one time to have H2 products listed doesnt exist now, and I have never heard a good argument in favor of it.

Industry doesnt need to use H2 lubricants, he reiterates. They can use whatever they want if theres no chance of food contact. And where theres a chance of food contact, use H1.

Jessica Evans says the topic is sure to be aired on Oct. 16, when NSF holds its yearly stakeholders meeting for its nonfood compounds registration program. The past two meetings focused more on food regulations in general, she says. But H2 not-quite-food-grade lubes could be on the front burner this year.